FuelEU Pooling Service

    FuelEU Maritime compliance advisory and implementation support for shipowners and operators.

    Our service focuses on FuelEU Maritime pooling: assessing each vessel's compliance balance, matching compliance surplus with deficit, and coordinating contracting and pool registration end-to-end with support from Tecway Maritime.

    FuelEU Maritime pooling – vessels connected in a compliance pool

    FuelEU Maritime Overview

    From 2025, FuelEU Maritime applies to commercial passenger and cargo ships exceeding 5,000 GT calling at EU ports, irrespective of flag and subject to the exceptions set out in the Regulation. It limits the well-to-wake annual greenhouse gas intensity of the energy used on board, covering CO₂, CH₄ and N₂O.

    Compliance Status

    Compliance surplus

    The vessel's annual GHG intensity is below the required limit, producing a compliance surplus that may be used within the FuelEU framework, including pooling.

    Zero balance

    The annual GHG intensity meets the required limit, so no surplus is generated. A zero GHG intensity balance does not in itself guarantee that all FuelEU obligations are met or that no penalties apply.

    Compliance deficit

    The annual GHG intensity exceeds the required limit. A remaining compliance deficit after application of available flexibility mechanisms may give rise to a FuelEU penalty. Payment does not itself eliminate the deficit or reduce emissions.

    Pooling and penalty cost comparison

    The comparison below is indicative. Actual figures depend on each vessel's verified compliance deficit and the specific commercial terms agreed.

    Recommended

    Pooling

    Optimising compliance costs

    Where supported by the specific quotation and contractual terms, pooling costs can be kept at or below 40% of the equivalent amount of a direct FuelEU penalty. The actual level is subject to the vessel's compliance deficit assessment and the final quotation.

    Paying the Penalty

    Approx. EUR 640 / tCO₂eq

    An illustrative equivalent cost per tonne of compliance deficit under specific assumptions on actual GHG intensity — not a universal statutory rate. The penalty payable is calculated in accordance with Annex IV of the Regulation, with the consecutive reporting-period multiplier applied where relevant.

    Basis of the figure: assuming an actual GHG intensity of 91.16 gCO₂eq/MJ, 2,400 × 10⁶ ÷ (41,000 × 91.16) ≈ 642, rounded to approx. 640 EUR/tCO₂eq, excluding any repeat non-compliance multiplier. Where a ship records a compliance deficit in n consecutive reporting periods, the calculated penalty is multiplied by 1 + (n − 1) / 10.

    How We Help with Pooling

    Utilising Pooling

    1. 1Calculate your compliance balance — our team supports the calculation, including forecasts of requirements.
    2. 2Match surplus with deficit — we connect companies holding a compliance surplus with companies facing a compliance deficit to form a pool, creating additional value for surplus parties and reducing penalty exposure for deficit parties.
    3. 3Coordinate and track — we coordinate the pool, track compliance status and assist with registering vessels in the pool in the FuelEU database, or use the infrastructure of pooling partners.

    Pooling Conditions

    • A pool must include at least two ships, which may belong to the same company or to different companies.
    • A ship's GHG intensity compliance balance may be allocated to only one pool per reporting period.
    • The total compliance balance of the pool must be positive.
    • A ship with an initial deficit may not see that deficit increased, and a ship with an initial surplus may not end up in deficit after allocation.
    • The participating companies validate the pool, and the selected accredited verifier verifies the final allocation of compliance balances.
    • Borrowing of an advance compliance surplus is not permitted for ships included in a pool.

    Deadline: The final composition of the pool and the allocation of compliance balances must be recorded by the verifier in the FuelEU database by 30 April of the verification year. Commercial contracting, document submission and pool entry arrangements normally need to be completed earlier; the applicable cut-off dates follow the requirements of the specific pooling scheme.

    Tecway Maritime supports the calculation of compliance balances, the matching of surpluses and deficits, and the coordination and execution of pooling arrangements.

    Download Product Brochure

    Contact Us

    Tecway Maritime Technology Limited

    Units 9 & 10, 25/F., Peninsula Tower538 Castle Peak Road, Cheung Sha WanKowloon, Hong Kong S.A.R.

    Tel: +852 3543 1912

    info@tecwayintl.com

    Agency Territory: Mainland China, Hong Kong